Justin William Pagel, a stockbroker previously registered with Feltl Company in Plymouth, Minnesota, has been sanctioned by Financial Industry Regulatory Authority (FINRA) for making unsuitable investment recommendations and engaging in unauthorized trading. Letter of Acceptance, Waiver, and Consent No. 2022073340901 (January 17, 2025).
According to the AWC, Pagel managed accounts for Customers A, B, and C, who were single parents facing financial difficulties. Their investment funds came from inheritances or charitable gifts, and they had no prior investment experience. They instructed Pagel to invest conservatively to cover future expenses like a home purchase or college tuition. However, Pagel directed them to select aggressive investment objectives and high-risk tolerances in their account documents, allowing him to invest their money in speculative securities.
As a result of Pagel’s recommendations, these customers invested most or all their assets in highly speculative stocks, leading to financial losses and customer complaints. The trading activity in their accounts occurred from 2014 to 2019, and Feltl Company paid $26,000 to resolve two complaints.
In November 2022, Pagel managed accounts for Customer D, who had a modest income and net worth and no investment experience. Customer D requested safe investments and selected a moderate risk tolerance on his account forms. Despite this, Pagel recommended speculative securities inconsistent with Customer D’s financial profile.
Pagel’s unsuitable recommendations to Customers A, B, and C violated FINRA Rules 2111 and 2010. His recommendations to Customer D violated Reg BI’s best interest standard, as well as FINRA Rule 2010.
Additionally, Pagel exercised discretion in customer accounts without proper authorization. FINRA Rule 3260(b) prohibits brokers from making discretionary trades without written consent from both the customer and the firm. From July 2019 to December 2023, Pagel executed 360 trades across 47 customer accounts without authorization, violating FINRA Rules 3260(b) and 2010.
Furthermore, Pagel inaccurately reported trades by marking solicited trades as unsolicited. FINRA Rule 4511 requires brokers to maintain accurate records, and falsifying trade records violates this rule. From April 2013 to January 2022, Pagel mismarked 587 solicited trades as unsolicited across more than 50 accounts, including those in which he exercised unauthorized discretion. This misconduct resulted in violations of FINRA Rules 4511 and 2010.
Pagel consented to a ten-month suspension beginning January 21, 2025, and ending November 20, 2025.
FINRA Public Disclosure shows that five customer disputes have been filed against Pagel throughout his career. On September 8, 2020, a customer filed an investment related complaint alleging unsuitable investment recommendations, misrepresentation of material fact, and breach of fiduciary duty, claiming losses of approximately $68,200. The case was settled on January 13, 2021, for $16,000. Also, a customer initiated investment related FINRA securities arbitration claim, filed on August 8, 2013, alleged breach of fiduciary duty and unsuitable recommendations in Cornerstone Industrial Properties Leveraged Fund Advisors LLC. The customer asserted that Pagel misrepresented the investment’s risks and expected returns. This case was settled for $55,000 on September 25, 2014. FINRA Arbitration No. 13-02090.
Another customer initiated investment related complaint filed on September 14, 2018, alleged unsuitable recommendations and excessive trading from January 2014 to December 2015. This complaint, which sought $35,000 in damages, was denied on August 7, 2020.
Pagel’s employment history includes associations with several brokerage firms. From August 2011 to May 2024, he was registered with Feltl Company in Plymouth, Minnesota.
